How to Create an Invoice Without GST Registration in India
Not registered under GST? You can still bill clients. Learn what to call the document, which fields to include, what to leave out, and see a sample invoice.
Quick answer
Yes, you can invoice clients without GST registration. Call the document an "Invoice" (not a "Tax Invoice"), do not charge or show GST, and include a line such as "Supplier not registered under GST". Everything else that makes an invoice professional still applies: a unique number, date, client details, clear line items, total and payment terms.
Who can work without GST registration
In most states, a supplier of services does not have to register until aggregate turnover crosses ₹20 lakh in a financial year (₹10 lakh in special category states). Suppliers of goods only have a higher limit of ₹40 lakh in most states. Some businesses must register regardless of turnover, for example those making inter-state supplies of goods, selling through e-commerce operators in certain cases, or liable under reverse charge.
Turnover here means aggregate turnover across all your businesses under the same PAN, including exempt supplies. If you are unsure where you stand, confirm with a chartered accountant.
What to call the document
Only a registered person can issue a tax invoice. If you are unregistered, title your document "Invoice" or "Bill". Do not use "Tax Invoice" and do not show a GSTIN, because you do not have one.
Fields to include
- Your name or trading name, address, email and phone
- Your PAN (useful if the client deducts TDS)
- Invoice number and date
- Client name, address and, if they are registered, their GSTIN
- Description of each service or item, quantity and rate
- Total amount in figures and words
- Payment terms, due date and bank or UPI details
- A note: "Supplier not registered under GST. GST not charged."
- Signature
Fields to leave out
- GSTIN (yours)
- CGST, SGST or IGST lines
- Any wording that suggests tax is included
Charging GST without registration is not allowed. If a client asks you to "add GST", explain that you are not registered and the amount you bill is the full amount.
Worked example
Neha is a freelance content writer in Indore with annual receipts of about ₹9 lakh. She is not registered under GST. In October she writes 10 blog posts for a Delhi-based SaaS company at ₹2,500 each.
- Invoice number: NK-0042
- Invoice date: 5 November 2026, due 20 November 2026
- Blog articles (1,200 words each), 10 at ₹2,500 = ₹25,000
- Total: ₹25,000 (Rupees Twenty-Five Thousand Only)
- Note: "Supplier not registered under GST. GST not charged."
- PAN: shown below her address
If her client deducts TDS (for example on professional fees above the yearly threshold), the client pays her less than ₹25,000 and the deducted tax shows as a credit against her PAN. That is an income tax matter and does not change what her invoice shows.
A sample layout
| Section | What to write |
|---|---|
| Title | Invoice |
| From | Neha, content writer, Indore, Madhya Pradesh · PAN |
| Bill to | Client's legal name, address and GSTIN (if registered) |
| Invoice no. and dates | NK-0042 · 5 Nov 2026 · Due 20 Nov 2026 |
| Line item | Blog articles (1,200 words each), 10 × ₹2,500 = ₹25,000 |
| Total | ₹25,000 (Rupees Twenty-Five Thousand Only) |
| Note | Supplier not registered under GST. GST not charged. |
| Payment | Bank account, IFSC, UPI ID |
Unregistered versus composition scheme
These are different. An unregistered supplier has no GSTIN and issues an ordinary invoice. A supplier registered under the composition scheme does have a GSTIN, pays tax at a fixed rate on turnover, cannot collect GST from customers and issues a bill of supply instead of a tax invoice. If you have opted for composition, your document should say so.
Clients who insist on GST invoices
Some companies prefer registered suppliers because they want input tax credit. You have two options: explain that you are below the threshold, or register voluntarily. Voluntary registration means you must charge GST, file returns and keep compliant records, even if your turnover stays low. Weigh the paperwork against the business you would win.
When you cross the threshold
Track your receipts monthly. Once you approach the threshold, apply for registration: the law gives you 30 days from the date you become liable. After registration, switch to tax invoices with a new numbering series, and keep the old non-GST invoices on record.
Common mistakes
- Adding "GST 18%" to look professional while unregistered.
- Using the title "Tax Invoice".
- Not tracking turnover, then discovering late that registration was due.
- Missing PAN, which causes TDS credit problems.
Frequently asked questions
Is an invoice without GST valid?
Can I mention my Udyam registration number?
Do I need to show HSN or SAC codes?
Next step
Create your next invoice with the fields above and the "Supplier not registered under GST" note. If you are close to the threshold, speak to a CA before you cross it.